The Health Resources Services Administration (HRSA) recently opened an application process for $25.5 billion in federal COVID-19 funding for providers. The same application process is used for both Provider Relief Fund (PRF) Phase 4 and American Rescue Plan (ARP) Rural payments.
The PRF Phase 4 funding is open to a broad range of providers with changes in operating revenues and expenses due to the pandemic. ARP Rural funding is open to providers who serve rural beneficiaries of Medicare, Medicaid or the Children’s Health Insurance Program, known in Michigan as MIChild.
Additional information, including eligible provider types and application instructions, is available on the HRSA website. The agency must receive applications by Oct. 26, and members are encouraged to begin the process as soon as possible. Registration for webinars featuring guidance on using the application portal are also listed online. HRSA intends to start distributing the ARP funds by late November and the PRF funds by mid-December.
The Centers for Medicare & Medicaid Services (CMS) recently included proposals related to the quality reporting programs for long-term care hospitals (LTCHs) and inpatient rehabilitation facilities (IRFs) in its proposed rule to update the Medicare fee-for-service prospective payment system for home health agencies (see related article). LTCHs and IRFs were initially scheduled to begin reporting two new quality measures Oct. 1, 2020, including Transfer of Health Information to the Provider and Transfer of Health Information to the Patient, as well as several standardized patient assessment data elements (SPADES).
Due to the COVID-19 public health emergency (PHE), the CMS declined to release updated versions of the patient assessment tools necessary for reporting this information and delayed the compliance date for reporting these items until Oct. 1 of the year that is at least one full fiscal year after the end of the COVID-19 PHE. The CMS proposes to require reporting of these measures and SPADES beginning Oct. 1, 2022, since COVID-19 cases and deaths have declined. The MHA encourages LTCHs and IRFs to submit comments to the CMS regarding this provision by Aug. 27. Members with questions should contact Vickie Kunz at the MHA.
The Centers for Medicare & Medicaid Services (CMS) recently released a proposed rule to update the Medicare fee-for-service prospective payment system for home health (HH) agencies effective Jan. 1, 2022. Key aspects of the proposal include:
Expanding the HH value-based purchasing model nationally to replace the pilot that began in nine states (AZ, FL, IA, MD, MA, NE, NC, TN, WA) in 2016.
Increasing the national, standardized 30-day HH payment rate by 5.9% from $1,901.12 to $2,013.43 for HH agencies that submit the required quality data.
Recalibrating the Patient-driven Groupings Model (PDGM) case-mix weights for the 432 payment groups using 2020 data.
Updating the HH quality reporting program to:
Remove the Outcome and Assessment Information Set (OASIS)-based Drug Education on All Medications Provided to Patient/Caregiver During All Episodes of Care measure.
Replace two claims-based measures, the Acute Care Hospitalization During the First 60 Days of Home Health (NQF #0171) measure and Emergency Department Use without Hospitalization During the First 60 days of Home Health (NQF #0173), with one claims-based measure, Home Health Within Stay Potentially Preventable Hospitalization.
Modifying HH aide supervision requirements to make permanent the regulatory blanket waivers related to HH aide supervision that were issued during the COVID-19 pandemic.
Implementing a provision of the Consolidated Appropriations Act that would allow occupational therapists to perform the initial and comprehensive patient assessment.
Continuing the 4.36% behavioral adjustment reduction to the standardized 30-day payment rate implemented in 2020 when the new PDGM was adopted.
Consistent with other recent proposed rules, the CMS included two requests for information:
The use of fast healthcare interoperability resources in support of digital quality measurement in quality reporting programs.
Closing the health equity gap on ways to attain health equity for all patients.
Members are encouraged to review the proposed rule and submit comments to the CMS by Aug. 27. The MHA will provide members with an estimated impact analysis within the next few weeks. Those with questions should contact Vickie Kunz at the MHA.
The Michigan Department of Health and Human Services (MDHHS) Omnibus Budget Reconciliation Act (OBRA) office recently announced a delay from late August until Sept. 20 for the effective date of its new electronic system for completing forms 3877 and 3878. The delay is in response to the MHA’s advocacy efforts and input from hospitals. Registration for the system will be open Aug. 16, providing more than 30 days for providers to register.
The new electronic system will replace the current paper process for completing the forms, which are required for discharging certain patients from an inpatient hospital to post-acute care settings such as skilled nursing facilities.
The MHA encourages all facilities to be prepared for the following dates:
Aug. 6: “Sandbox” testing environment closes.
Aug. 16: Live registration begins.
Sept. 20: Statewide go-live date.
The MDHHS OBRA office is updating each User Role training module and will post them on the MDHHS-OBRA webpage as they become available over the coming weeks. The first training added will be for the 3878 User Role.
The MHA continues to convene a work group to identify issues and provide input to the OBRA office. Members with specific questions should contact the OBRA Help Desk. General questions may be directed to Vickie Kunz at the MHA.
The Centers for Medicare & Medicaid Services (CMS) released a proposed rule to update the Medicare fee-for-service prospective payment system (PPS) for skilled nursing facilities (SNFs) for fiscal year (FY) 2022, which begins Oct. 1, 2021.
Key provisions of the proposal would:
Increase the standard federal rate by a net 1.3% for SNFs that comply with the quality reporting program (QRP) requirements. SNFs that fail to submit data are subject to a 2 percentage point reduction in their annual update.
Update the diagnosis code mappings in the Patient Driven Payment Model case-mix system implemented in FY 2021.
Reduce the labor-related share of the federal rate from 71.3% to 70.1%.
Modify the denominator for the Transfer of Health Information to the Patient – Post-acute Care measure in the SNF QRP to exclude patients discharged home under the care of a home health or hospice provider and add two new quality measures beginning with the FY 2023 QRP:
The SNF Healthcare Associated Infection Requiring Hospitalization measure.
The COVID-19 Vaccination Coverage among Healthcare Personnel measure.
Suppress the SNF 30-Day All-cause Readmission Measure for the FY 2022 SNF value-based purchasing program year due to the public health emergency (PHE), which significantly impacted the measure and resulting performance scores.
Reduce the number of quarters for publicly reporting SNF QRP measures due to the PHE.
The CMS is working to make healthcare quality more transparent to consumers and providers. Included in the proposed rule is a request for input on ways to attain health equity for all patients through policy solutions as demonstrated through the adoption of the standardized patient assessment data elements (SPADEs) in the FY 2020 SNF final rule. These elements include several social determinants of health. The CMS seeks feedback on the possibility of expanding measure development and the collection of other SPADEs that address gaps in health equity in the SNF PPS. The CMS also seeks input on the potential use of Fast Healthcare Interoperability Resources in support of Digital Quality Measurement in QRPs, aligning with other quality programs where possible.
The CMS will accept comments on the proposed rule until June 7. The MHA will provide SNFs with an estimated impact analysis and summary of the proposed rule soon. Members with questions should contact Vickie Kunz at the MHA.
The Centers for Medicare & Medicaid Services (CMS) released a proposed rule to update the Medicare fee-for-service prospective payment system for inpatient rehabilitation facilities (IRFs) for fiscal year (FY) 2022, which begins Oct. 1, 2021.
Key provisions of the proposal would:
Increase the standard federal rate by 2.5% from $16,856 to $17,273 for facilities that comply with the IRF quality reporting program (QRP). Facilities that fail to comply are subject to a 2 percentage point reduction.
Increase the cost outlier threshold by 16% from $7,906 to $9,192, resulting in fewer cases qualifying for an outlier payment.
Modify the IRF QRP by:
Proposing the addition of the COVID-19 Vaccination Coverage among Healthcare Personnel (HCP) measure, requiring IRFs to report HCP vaccinations in their facilities.
Updating the denominator for the Transfer of Health Information to the Patient-Post Acute Care quality measure to exclude patients discharged home under the care of a home health or hospice provider.
Updating the number of quarters of data used for public reporting to account for the COVID-19 public health emergency reporting exception granted for Jan. 1 – June 30, 2020.
As it works to make healthcare quality more transparent to consumers and providers, the CMS is seeking input on ways to attain health equity for all patients through policy solutions, as demonstrated by the adoption of standardized patient assessment data elements (SPADEs). These data elements include several social determinants of health that were finalized in the FY 2020 final rule for the IRF QRP. Through a Request for Information within the proposal, the CMS is seeking comment on expanding measure development and the collection of other SPADEs that address health equity gaps. The agency also seeks feedback on its plans to define digital quality measures for the IRF QRP and the potential use of fast healthcare interoperability resources within the IRF QRP, aligning with other quality programs where possible.
The CMS will accept comments on the proposed rule until June 7. The MHA will provide IRFs with an estimated impact analysis and summary of the proposed rule within the next month. Members with questions should contact Vickie Kunz at the MHA.
The MHA continues to keep members apprised of pandemic-related developments affecting hospitals through email updates and the MHA Coronavirus webpage. Important updates are outlined below.
COVID-19 Cases Continue to Surge in Michigan
New cases of the coronavirus and related hospitalizations have recently ranked Michigan as having the most severe surge of viral spread in the nation. Gov. Gretchen Whitmer urged vaccination providers March 29 to inoculate anyone they can accommodate, regardless of age or health status, to mitigate the spread and ensure no doses are wasted. State officials continue to encourage vaccinators to prioritize doses among all recipients to ensure that medically frail or otherwise more vulnerable individuals are protected.
As the MHA reported in a March 24 news release, hospitalization rates are increasing rapidly for younger age groups that are less likely to have been vaccinated, while the vaccine appears to be preventing hospitalizations at or near 100%. MHA Chief Medical Officer Gary Roth, DO, discussed the need for Michigan residents to improve preventive measures and get vaccinated during an interview on CNN’s New Day program March 30. Additional media coverage of the increasing hospitalizations is outlined in a related article.
The governor announced March 31 that Michigan’s state allocation of vaccines will exceed 620,000 during the week of April 5. That figure does not include vaccines that will be sent to Michigan retail pharmacies and federally qualified health centers directly from the federal government.
Vaccinating Michiganders became even more important when a Bay County resident tested positive March 31 for the COVID-19 variant that originated in Brazil (P.1). The Bay County Health Department is taking all appropriate measures to identify the source of the infection, which is known to be more transmissible than the original virus. Hospitals are encouraged to continue communicating with their patients and communities about variants present in Michigan to urge continued mask wearing, distancing, hand washing and vaccination.
For more information about the COVID-19 vaccines, contact Ruthanne Sudderth at the MHA.
Medicare Claims Held as Congress Considers Extending Sequestration Moratorium
The Centers for Medicare & Medicaid Services recently instructed Medicare Administrative Contractors (MACs) to hold all Medicare fee-for-service claims for dates of service on or after April 1, 2021, for a short period in anticipation of possible congressional action to extend the moratorium on the 2% sequestration cut to all Medicare payments. Absent congressional action, the moratorium was to expire April 1, reinstating the cuts.
The U.S. Senate recently passed a bill that, among other provisions, would eliminate the 2% cut to all Medicare payments until the end of 2021. The U.S. House is expected to take up the Senate-passed bill when it returns to session the week of April 13.
If necessary, the MACs will automatically reprocess any claims paid with the reduction applied. Elimination of the sequester cuts was included in the CARES Act and was effective from May 1 through Dec. 31, 2020; it was subsequently extended through March 31, 2021.
The MHA, along with the American Hospital Association and others, continues to advocate for payment policies that support COVID-19 relief and recovery. Those wishing to urge their representative to support an additional extension of the moratorium on the 2% sequestration cuts can obtain their lawmaker’s contact information at the MHA Legislative Action Center by entering their ZIP code into the “Find Officials” field. Members with questions should contact Vickie Kunz at the MHA.
New Resources on Therapeutic Options Available on MDHHS Website
The Michigan Department of Health and Human Service (MDHHS) has posted new resources on the variety of therapeutics available to treat COVID-19. The information includes the types of therapies available, how to prescribe and administer them, how to order them and more. The website also allows individuals who want to receive antibody treatment to locate treatment near them. The MDHHS encourages all providers to actively seek out COVID-19-positive individuals to whom they can provide therapeutic treatments.
Clinic Preparation for Vaccination Webinar Materials Posted
The MDHHS has made available the recording and materials from its March 26 webinar for those who wish to vaccinate patients in physician office/clinic settings. Materials include a checklist that outlines all steps the clinic must have in place to receive, administer, bill for, store, prepare and document COVID-19 vaccines. The MDHHS provides materials from this and other relevant webinars on its COVID-19 Vaccine Webinars page in the provider education section of the website. Health systems that plan to redistribute vaccine to new sites or enroll new sites in the COVID-19 vaccination program are encouraged to share these materials with those offices to assist in preparation.